The U.S. Supreme Court on Monday declined to review a Fourth Circuit ruling that blocked a federal prisoner's constitutional challenge to a sentence enhanced under the formerly mandatory federal sentencing guidelines.

Jason Tywann Bell, who pled guilty to attempted bank robbery and a firearm charge in 2003 and served more than 20 years in prison, argued that his sentence was unconstitutionally increased under the guidelines' career offender provision, which raises sentencing ranges for certain repeat offenders.

Bell sought resentencing based on Johnson v. United States, the 2015 decision that struck down part of the Armed Career Criminal Act as unconstitutionally vague. He argued that the ruling's reasoning also applied to the identically worded residual clause in the career offender guideline used to enhance his sentence.

But in August 2025, a Fourth Circuit panel held that Bell could not pursue his challenge under Section 2241 of Title 28, which authorizes habeas corpus relief, because he could not satisfy the requirements for relief under Section 2255, the usual mechanism for federal prisoners to challenge their convictions or sentences.

Applying the Supreme Court's 2023 decision in Jones v. Hendrix, the panel held that those restrictions did not permit Bell to turn to Section 2241 and rejected his argument that denying him that avenue violated the Constitution's suspension clause.

Bell was sentenced to 22 years and 10 months in prison, followed by five years of supervised release, after a federal district court classified him as a career offender based on two prior convictions. Without that designation, his guidelines range would have been 14 years and eight months to 16 years and seven months, including the consecutive sentence for his firearm conviction.

Bell completed supervised release in December 2025, which made his habeas case moot before he could obtain Supreme Court review.

Bell then asked the justices to vacate the Fourth Circuit's judgment, arguing in a March petition for certiorari that leaving the ruling intact would bind similarly situated federal prisoners, even though Bell was prevented from seeking further review.

"The ruling below leaves certain federal prisoners with no forum to press a constitutional sentencing challenge," he wrote in the petition.

Bell invoked Munsingwear vacatur, a doctrine named for the Supreme Court's 1950 decision in United States v. Munsingwear Inc. It allows courts to set aside judgments when a case becomes moot before appellate review can be completed, preventing an unreviewable judgment from continuing to "spawn" legal consequences.

To determine whether to grant vacatur, courts look at various factors, including how the case became moot.

Bell argued that he had diligently pursued his challenge and that completing his supervised release should not leave an adverse ruling binding on other prisoners without an opportunity for Supreme Court review.

The government opposed vacatur, arguing in a brief opposing certiorari that the underlying case did not warrant Supreme Court review in the first place, and that the Fourth Circuit affirmed the dismissal of Bell's case on jurisdictional grounds. It also argued that Bell contributed to the case becoming moot by seeking early termination of his supervised release.

Bell countered in a reply brief that when, without the help of an attorney, he made a motion to terminate his supervised release earlier after obtaining habeas relief on a different basis, he did not abandon or manipulate the appellate review process.

"By then, petitioner had already served the longer custodial sentence and had overserved 2,422 days — nearly seven years," Bell said, adding that he was not required to remain under supervision solely to preserve review at the Supreme Court.

Counsel for Bell did not reply to a request for comment following the cert denial. A representative for the U.S. Department of Justice declined to comment.

Bell is represented by Dana Kagan McGinley of Arnold & Porter.

John Gilley is represented by U.S. Solicitor General D. John Sauer.

The case is Bell v. Gilley, case number 25-1141, in the Supreme Court of the United States.

--Additional reporting by Elizabeth Daley. Editing by Marygrace Anderson.